AAFCO January 2017 Meeting Notes

Here are the details of what happened during the January 2017 AAFCO meeting.

The two biggest sessions that relate to pet food issues are the Pet Food Committee and Ingredient Definitions Committee meetings. To back up a bit – giving explanation of how AAFCO works…AAFCO meetings are a series of individual committee meetings within AAFCO. Because AAFCO writes the (state) regulations of all animal foods, there is a lot involved. A brief example…cat food and dog food is required to meet a minimum protein amount. The Pet Food Committee established that minimum protein level. But to enforce that legal minimum protein level, state feed/pet food laboratory authorities have to be able to consistently test a pet food (all states testing the same way) to make sure the minimum protein level is met. So another committee is Laboratory Methods and Services Committee which establishes those testing methods for the states to use (making sure everyone is consistently testing pet foods in the same manner). In other words there is a lot involved in regulating pet food – it is not a simple situation.

During the Pet Food Committee session (Tuesday January 17, 2017) the definition of ‘pet food’ was discussed. The definition presented was: ‘The term pet food means any commercial feed prepared and distributed for pets.’ It is significant for consumers to know that pet food – as a whole – is not food…it is feed. Feed is not regulated in the same manner as food, feed falls under a completely different set of regulations – all of which are not public information (they are owned by AAFCO) and they vary from state to state. The only exception of pet feed would be a human grade pet food (manufactured in a human food facility, made with human grade ingredients and supplements). All other pet foods…are not food.

The term ‘Pet’ will be defined as a cat or dog. All other pets (such as pet birds, hamsters, ferrets, etc.) are termed as ‘Specialty Pet’. (Yes…all of these things have to be clearly defined in law.)

Another discussion that took place during the Pet Food Committee session was on Dental treat/food claims – such as a treat that is marketed to reduce tartar build up on a cat or dogs teeth. One of the things that will be required of these treats/foods will be disclosure of how this tartar reduction occurs – is the tartar reduction performed by a chemical means or by means of mechanical action (abrasion). The example given was a treat that has “ridges”. I asked a State Department of Agriculture representative this question about those ‘ridges’: So…Ruffles Potato Chips have ‘ridges’…does this mean that they could be sold touting those ‘ridges’ clean a dog or cat’s teeth? The response was basically yes; as long as the company makes the claim those ridges are there for the abrasive mechanical action to clean a dog or cat’s teeth…yes they can make that claim.

The lesson learned for consumers with this issue, is if you are purchasing a cat or dog treat for the purpose of cleaning your pet’s teeth, call or email the manufacturer and ask them to send you the documentation (scientific evidence) to the effectiveness of the dental treat (Ruffles have ridges, but they don’t clean teeth).

Another interesting thing that happened during the Pet Food Committee session was regulatory authorities asking other regulatory authorities (one state asking other states) what they do in the situation of new changes in pet food nutrient profiles. As example, in very recent years at AAFCO the calcium requirement for large breed puppy food was lowered (lowering the calcium to slow the bone growth – not wanting bones to grow too rapidly). Some states adopted the new requirement of lowered calcium in large breed puppy food immediately – but many other states have not (some have not updated their laws since the 1970’s). The question was asked to all regulatory authorities – what do you do? What do you do when you get a pet food label in – that meets the new requirement with (as example) calcium in large breed puppy food but it doesn’t match your current state law? Overall the response was regulatory authorities use ‘enforcement discretion’ and allow the new lowered calcium large breed puppy food even though their state laws are not requiring the lowered calcium.

Consistent laws governing pet food – from state to state – is VERY much needed. We don’t have that right now – and we need it. Concerned pet food consumers, please write your Governor and ask him/her to properly update all feed/pet food laws to be consistent each year with AAFCO. States earn a great deal of sales tax revenue from pet food/treat/supply sales – and pet food consumers deserve this from our government. Many State Department of Agriculture’s have one or two people overseeing everything animal food – they simply cannot protect pet food consumers properly with such a limited staff. State government is not funding these agencies properly – and it is up to us (pet food consumers) to complain. Again – each State earns a significant income from sales tax on these products…we deserve better.

During the Ingredient Definitions Committee session, we visited an ingredient that was discussed several years back. For those that have followed my AAFCO meeting notes for years, you might remember my discussion of a zinc ingredient AAFCO Ingredient Definitions Committee approved several years back; Zinc Hydroxychloride. Three veterinarians spoke out against the approval of this ingredient, but AAFCO approved it anyway (and several folks that spoke out against it were yelled at – called ‘hippie vegetarians’ by the company pushing the ingredient through). The final approval of the ingredient just took place at this meeting (each ingredient has to go through several steps which do take years for final approval). Zinc Hydroxychloride – allowed by AAFCO – can contain up to “Lead – 90 ppm (parts per million), Arsenic – 10 ppm, and Cadmium – 10 ppm”. Just to give you an example of how extreme that is – another supplement that received final approval was “Zinc Propionate”. The legal limits of pollutants in Zinc Propionate are “Lead – less than 0.5 ppm, Arsenic – less than 1 ppm, Cadmium – less than 1 ppm”.

Zinc Propionate – Lead – less than 0.5 ppm, Arsenic – less than 1 ppm, Cadmium – less than 1 ppm

The lead, arsenic and cadmium filled zinc hydroxychloride ingredient was approved during the Ingredient Definitions Committee session to be included in chicken feed (it was already approved to be included in pet food and cattle feed). No evidence was provided at the meeting proving the lead, arsenic or cadmium levels in this ingredient would not be toxic to pets nor was new evidence provided that (example) meat from chickens consuming this supplement would not contain high lead levels. The State Department of Agriculture representative that submitted this ingredient to include chicken feed stated he had “no issues”. But…here’s the thing…most individuals with State Department of Agriculture are not qualified/trained to interpret scientific research to the safety of an ingredient (containing significantly high levels of lead). This is where the system often fails. These ingredients need to be passed by a team of scientific animal food/pet food researchers – not State Department of Agriculture with too much work to do. Watch out for this ingredient in your pet’s food – if you are doing extra due diligence with your pet’s food and your food – ask the meat provider (farmer) if the chicken or beef (or any other meat/fish) was provided a feed that included zinc hydroxychloride.

Another discussion of interest during this session was ‘common human foods in pet food’. The example given was hemp/hemp hearts. But I added to the discussion cricket meal. With human food, if a new ingredient is used in a food the ingredient has to be submitted to FDA for safety consideration. Once that safety approval is achieved, the new ingredient (such as hemp hearts or cricket meal) any food can use that ingredient. But with pet food, a new ingredient must go through the AAFCO process.Safety data specific to species (poultry, cattle, cats, dogs, etc.) would be submitted to a State Feed Official, and then the request for a legal definition of the ingredient must be filed. This process often takes years and often manufacturers choose to ignore the AAFCO requirement. Pea protein is the perfect example. Pea protein was defined just a couple of years ago (made legal for use in pet food), but many, many pet food manufacturers chose to use the ingredient long before (for at least 10 years). That fiasco was sort of an embarrassment (my opinion) to regulatory authorities – they let things get out of control expecting manufacturers to abide by the rules and that certainly is not what happened. So the discussion at AAFCO was – sort of – letting manufacturers know, they will not let the pea protein incident happen again. When I asked if treats and pet foods containing cricket meal would be pulled from store shelves – without hesitation one regulatory authority said “Yes”. This is good news. Every pet food/treat manufacturer should be very familiar with the regulations that govern their industry and they should abide by those rules. But when they don’t, we need regulatory to step in and ‘educate’ them to the legal process.

We also had a meeting of our Pet Food Label Modernization Working Group during AAFCO. But…AAFCO does not allow me to share anything with consumers about our progress. I can share that I don’t like (not one bit) some of the things that are happening. All I can say.

Again I want to thank Dr. Cathy Alinovi, Roxanne Stone, Nina Wolf and BC Henchen for being at AAFCO. I cannot properly explain how grateful I am to have all of you there (this meeting especially).

From right to left…Dr. Cathy Alinovi, Nina Wolf, BC Henchen, me, Roxanne Stone and Billy (don’t have his last name).

The next public AAFCO meeting takes place in August in Bellevue, Washington. Between now and then there will be dozens of webinar meetings I will attend – most of which I am not allowed to share with consumers. What I can share – will be shared. (You deserve to know.) My thanks to everyone that supports this website and our consumer association – without your support, I wouldn’t be at AAFCO. So BIG thanks to everyone!

Hi Cara – pet food is rarely regulated, crossing state line or not. And actually – smaller brands are more likely to be tested (raw) and scrutinized by regulatory than larger manufacturers. FDA and each of the 50 states openly allows all brands to violate federal laws. Unfortunately buying bigger name foods does not eliminate concern.

It seems as though they have been in stasis about definitions for aeons. Maybe it’s the only thing in their pitiful lives that makes them feel their existence is justified and important. I don’t know how you do it, Susan. I really don’t. As I wrote once before, there’s a special place in heaven for you. There’s also a special place in hell for those who harm God’s creatures. Great photo. Glad you’re back safe and sound.

How you stated your comment doesn’t make any sense. Any infection of that proportion, no matter the origin, being so easily transmitted, is an issue. Like maybe through air travel? If I should be “more” concerned about what just seems familiar to us… not likely. Absent of personal hygiene and other quality assurances, imported food ingredients aren’t safe. And what Batzion has pointed out, is yet another complication.

“The definition presented was: ‘The term pet food means any commercial feed prepared and distributed for pets.’ It is significant for consumers to know that pet food – as a whole – is not food…it is feed. Feed is not regulated in the same manner as food, feed falls under a completely different set of regulations – all of which are not public information (they are owned by AAFCO) and they vary from state to state. The only exception of pet feed would be a human grade pet food (manufactured in a human food facility, made with human grade ingredients and supplements). All other pet foods…are not food’

Dumb question. But if pet food IS pet feed, why doesn’t AAFCO just deal with it that way. Wouldn’t it be to their advantage, even though of greater disadvantage to us.

It just doesn’t make any sense. If it’s not food, and it ISN’T, because a human can’t eat it, then how can they call it food at all??

Thank you Susan: You are extremly Heroic. Watch your back. You are exposing a lot of information that the Slaughter Chemical Drug Industry does not want exposed. Please be as careful as you can be when you are up against a very powerful industry that thinks very much about money and very little about Human or Non Human Life